WHEREFORE, Defendant Manafort respectfully requests that the Court transfer this case to Roanoke, Virginia for trial and asks the Court to adopt the procedures described above in its jury selection process.
His lawyers also claim a deferment is needed to compensate for time lost during his detention.
Manafort lamented in the filing that his indictment has been the subject of intense national media attention and claimed that the coverage "has often been sensationalized and untethered from the facts in the case".
Manafort's lawyer said Thursday he was being held in his cell 23 hours per day to "guarantee his safety" and can not adequately prepare for his upcoming trial later this month.
Manafort, according to his lawyer, is being secluded because correctional officials "cannot otherwise guarantee his safety".
Mr. Manafort submits that a fair trial will impossible without a change of venue to Roanoke, Virginia.
They cited voting data showing Hillary Clinton took two-thirds of the 2016 presidential vote in Alexandria, which was part of an "inside-the-Beltway" area preoccupied with political media coverage, much of it negative towards Manafort and Trump. While prosecutors filled in the Trump campaign details, Manafort's team was busy filing requests with the judge to move his trial location and date, to look into possible leaks from the prosecutors and to keep Manafort out of the public eye.
The financial crimes trial of Manafort is scheduled to start July 25 in Alexandria, Virginia, just outside Washington.
"Nowhere in the country is the bias against Mr. Manafort more apparent than here in the Washington, D.C. metropolitan area", Manafort's lawyers wrote. The jail is about a two-hour drive from Washington. Three others - George Papadopoulos, Michael Flynn and Rick Gates - have pleaded guilty and agreed to cooperate with investigators. Ellis made clear last week that Manafort's team wouldn't get a hearing on government leak accusations they've made before the trial, although it's possible a pretrial conference could be added to the schedule.
For instance, Manafort waived his right to appear in court for any upcoming hearings in the Eastern District of Virginia, his attorneys wrote in a filing Friday.
"He is locked in his cell for at least 23 hours per day - excluding visits from his attorneys", his defense lawyer Kevin Downing wrote in a brief filed Thursday, Courthouse News reports.
His lawyers told Jackson that the evidence of witness tampering was thin, and complained that Mueller's office had ignored another federal judge's order to turn over a complete list of potential witnesses.